# In Re Blue Cross Blue Shield Antitrust Litigation MDL 2406

> District Court, N.D. Alabama · August 9, 2022

URL: https://www.frixlaw.com/law-library/cases/9991246

## Case

- **Court:** District Court, N.D. Alabama
- **Decided:** August 9, 2022
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

## Citator (automated)

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## How later opinions describe it (automated extraction)

- discussing the legislative history of the Lanham Act

## Opinion text

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ALABAMA
SOUTHERN DIVISION

}
IN RE: BLUE CROSS BLUE SHIELD } Master File No.: 2:13-CV-20000-RDP
ANTITRUST LITIGATION }
(MDL NO.: 2406) }
}

MEMORANDUM OPINION AND ORDER ON DEFENDANTS’ MOTION REGARDING
THE ANTITRUST STANDARD OF REVIEW APPLICABLE TO PROVIDER
PLAINTIFFS’ SECTION 1 CLAIMS PURSUANT TO FEDERAL RULE OF CIVIL
PROCEDURE 56

This matter is before the court on Defendants’ Motion Regarding the Antitrust Standard of
Review Applicable to Provider Plaintiffs’ Section 1 Claims. (Doc. # 2722). The Motion has been
fully briefed. (Docs. # 2728; 2747; 2772).
This multi-district litigation has now entered its tenth year. But, even at this advanced stage
of the litigation, the court has not had the occasion to address “whether the Blue Plans’ service
area allocations alone constitute a per se violation of Section 1.” (Doc. # 2063 at 37). That is
because in the court’s April 2018 standard of review opinion (Doc. # 2063), the record before the
court presented it with “an aggregation of competitive restraints,” which included the National
Best Efforts (“NBE”) rule. The court concluded that combination of restrictions was to be analyzed
under the per se rule. (Id.). However, in April 2021, in connection with the settlement between the
Subscriber Plaintiffs and the Blues, Defendants eliminated the NBE rule.1 (Doc. # 2735-33). The
question now presented is whether the elimination of the NBE rule distinguishes this matter from

1 Defendants agreed as part of the settlement to eliminate the NBE rule, but did not await final approval and
unilaterally implemented that change in practice last year.
the aggregation of competitive restraints found in Sealy2 and necessitates a further analysis of
Topco.3 The answer is “yes.” As explained in more detail below, the court concludes that
Defendants’ new system is distinguishable from Sealy and Topco and that, for the period following
the elimination of the NBE rule (i.e., after April 2021), and for purposes of determining (or
evaluating) any structural relief, it must apply the rule of reason analysis to Providers’ Market

Allocation Conspiracy claims.
In their Motion, Defendants argue that the appropriate antitrust standard of review for
Providers’ challenges to the Blue Plans’ Exclusive Service Areas (“ESAs”) (their Market
Allocation Conspiracy claims) is the rule of reason, and that ESAs, alone, are not subject to the
per se rule for two primary reasons. First, Defendants contend that without NBE, there is no longer
an “aggregation of competitive restraints” similar to that addressed in the court’s April 2018
standard of review opinion. (Doc. # 2728 at 10). Second, Defendants assert that Providers’ claims
have “never involved an aggregation of restraints on branded and unbranded business.” (Id.).
Providers respond that (1) the elimination of NBE does not affect the standard of review

for the Providers’ claims from 2008 (the beginning of the limitations period) to April 2021 (when
NBE was eliminated), and (2) because Providers still seek injunctive relief to remedy the ongoing
effects of the NBE rule, the ESA and NBE rules can still be viewed in tandem for purposes of
determining the standard of review. (Doc. # 2747 at 6). Providers further argue that ESAs did not
“develop independently through existing trademark rights,” and, even if they did, their historical
origin makes no difference to the standard of review, as there is still “no daylight” between the
facts of this case and the Supreme Court’s decisions in Topco and Sealy. (Doc. # 2747 at 17, 19).

2 United States v. Sealy, 388 U.S. 350 (1967).
3 United States v. Topco Associates, Inc., 405 U.S. 596 (1972).
In their reply, Defendants assert that it was permissible to settle their trademark rights and
protect their trademarks through the license agreements containing the ESAs, and that alone
defeats per se treatment. (Doc. # 2772 at 6). Defendants further argue that a determination about
the legal effect of their ESAs, standing alone, implicates the rule of reason because they arose in a
novel factual context and offer procompetitive efficiencies. (Id.). Finally, Defendants argue that

the court’s April 2018 standard of review decision should not apply to Providers’ claims against
them because it was a Subscriber-focused ruling made at a time when the Subscriber and Provider
cases were joined, and Providers have no viable claim related to NBE. (Id.).
I. Background
The Blue Plans historically began with the development of prepaid hospital and medical
plans in the 1930s. (Docs. # 1353-4 at 21-22; 24; 1353-10 at 8-9). Local plans began using the
Blue Cross or Blue Shield symbol: the Blue Cross for prepaid hospital care was first used by the
St. Paul, Minnesota Plan in 1934; and the Blue Shield for prepaid medical care was first used by
the Buffalo, New York Plan in 1939. (Doc. # 1353-7 at 25-26, 63-64). Other Plans began using

these same symbols as well. (Docs. # 1350-35 at 2; 1349 at 11; 1431 at 15; 1435 at 12).
In 1938, the American Hospital Association (“AHA”) developed a program to grant
membership to local prepaid hospital plans. Forty plans were approved for membership, including
BCBS-AL’s predecessor, Hospital Service Corporation of Alabama (“HSC-AL”). (Compare Doc.
# 2728 at ¶ 12; Doc. # 2747 at ¶ 12). By 1938, the American Medical Association (“AMA”)
“endorsed [the] principle of ‘Medical service plans’” “and set forth guiding principles” for such
plans. (Doc. # 1353-5 at 36).
HSC-AL enrolled its first subscribers in 1936, and began using the Blue Cross mark in
1939 and the Blue Shield mark in 1947. This was after the AMA and the AHA had set their
respective standards for use of the marks. (Doc. # 2747 at 7). After 1939, HSC-AL continuously
used the Blue Cross mark. (Doc. # 2735; Doc. # 1353-13 at 12-3, 7-19). By 1949, BCBS-AL was
advertising its “medical-surgical” plan as the “Blue Cross – Blue Shield” plan, and it used both
the Blue Cross and Blue Shield marks together in commerce. (Doc. # 2735; Doc. # 1353-13 at 54-
56). So, by 1949, BCBS-AL was using both marks on a state-wide, exclusive basis. (Doc. # 2735;

Doc. # 1353-13 at 54-56). Other Blue Plans similarly used the Blue Cross and/or Blue Shield
marks in the 1930s and 1940s, but not always in an exclusive manner or on a state-wide basis.
(Doc. # 2747 at 7). Some Blues registered their marks locally. (Doc. # 2747 at 8).
In 1946, Congress enacted the Lanham Act, which provided national protection for
trademarks by virtue of federal registration. 15 U. S. C. §1051(a)(1). Given this change in law, the
Blue Plans and the national organizations discussed how best to protect their marks. (Doc. # 2735
-5 at 4; Doc. # 2735 at 6; Doc. # 2735-8). In 1947 and 1948, the national organizations applied for
federal registration of their Blue Cross and Blue Shield marks (collectively, the “Blue Marks”).
(Docs. # 1353-28; 1353-29; 1353-31; 1353-47; 1353-48 at 2; 2735-7 at 4; 2735-4 at 9).

Federal trademark registrations were issued to the national organizations in 1952. (Docs. #
1350-36; 1350-37; 1350-38; 1350-40; 1350-41; 1350-42; 1353-30). After the federal trademarks
were issued, the local Plans entered into written license agreements with the national organizations.
(See, e.g., Doc. # 1353-48; Doc. # 1353-50). The 1952 and 1954 license agreements confirmed
that the Plans had centralized local rights to the Marks in the national organizations and that the
national organizations, in turn, licensed the federal Blue Mark(s) back to each Plan. (Doc. # 1353-
48 at 2-4; Doc. # 1353-50 at 2-4). In areas where a single Blue Cross Plan had historically operated,
such use was deemed “exclusive”; but, in areas where multiple Plans had historically operated, the
license agreements reflected that reality with respect to those particular Plans. (See, e.g., Doc. #
1353-50 at 4).
In 1972, AHA transferred ownership of the Blue Cross Marks to the Blue Cross
Association (Doc. # 1353-57), and the Association issued new license agreements to the Plans.
(Doc. # 1353-100 at 2). In 1982, the Blue Cross Association merged with the Blue Shield

Association (formerly BSMCP) to create the Blue Cross and Blue Shield Association. (Doc. #
1353-10 at 33:10-24; Doc. # 1349-43 at 4-6; Doc. # 1349-27 at 44). In 1991, the Association
reissued License Agreements to the Plans. (See, e.g., Doc. # 1349-11 at 3; Doc. # 1349-12 at 3).
In 2005, the NBE Rule was adopted. It required a Blue Plan to derive at least sixty-six and
two-thirds percent of its national health insurance revenue from its Blue brands. In re Blue Cross
Blue Shield Antitrust Litig., 308 F. Supp. 3d 1241, 1256 (N.D. Ala. 2018) (citing Doc. # 1349-16
at 7). Thus, under NBE, any health revenue a Blue Plan generated from services offered under any
non–Blue brand was limited in relation to its Blue branded health revenue. Id. (citing Doc. # 1432
at 20–21). NBE did not specifically address contracting with Providers, nor did it place any limits

on contracting with Providers under non-Blue brands.
II. Standard of Review
Summary judgment is warranted if, viewing the facts in the light most favorable to the
nonmoving party, no material fact is subject to a genuine dispute. Matsushita Elec. Indus. Co. v.
Zenith Radio Corp., 475 U.S. 574, 585-87 (1986). The appropriate standard for evaluating conduct
challenged under the Sherman Act—rule of reason or per se—is a question of law for the court to
decide. Food Lion, LLC v. Dean Foods Co., (In re Milk Antitrust Litig.), 739 F.3d 262, 271 (6th
Cir. 2014) (“The district court’s decision to use the rule of reason is a question of law[], which we
review de novo.”). While the selection of a mode of analysis (per se or rule of reason) is a question
of law, sometimes “underpinning that purely legal decision are numerous factual questions.” In re
Wholesale Grocery Prods. Antitrust Litig., 752 F.3d 728, 733-34 (8th Cir. 2014).
III. Analysis
As the Supreme Court recently explained,
Section 1 of the Sherman Act prohibits “[e]very contract, combination in the form
of trust or otherwise, or conspiracy, in restraint of trade or commerce among the
several States.” 15 U.S.C. § 1. This Court has long recognized that, “[i]n view of
the common law and the law in this country” when the Sherman Act was passed,
the phrase “restraint of trade” is best read to mean “undue restraint.” Standard Oil
Co. of N.J. v. United States, 221 U.S. 1, 59–60, 31 S.Ct. 502, 55 L.Ed. 619 (1911).
This Court’s precedents have thus understood § 1 “to outlaw only unreasonable
restraints.” State Oil Co. v. Khan, 522 U.S. 3, 10, 118 S.Ct. 275, 139 L.Ed.2d 199
(1997) (emphasis added).
Ohio v. Am. Express Co., 138 S. Ct. 2274, 2283 (2018).
A restraint may be deemed unreasonable “either because it fits within a class of restraints
that has been held to be ‘per se’ unreasonable, or because it violates what has come to be known
as the ‘Rule of Reason.’” FTC v. Indiana Fed’n of Dentists, 476 U.S. 447, 457–58 (1986) (quoting
Chicago Bd. of Trade v. United States, 246 U.S. 231, 238 (1918)). “Determining whether a restraint
is undue for purposes of the Sherman Act ‘presumptively’ calls for what we have described as a
‘rule of reason analysis.’” Nat’l Collegiate Athletic Ass’n v. Alston, 141 S. Ct. 2141, 2151 (2021)
(quoting Texaco Inc. v. Dagher, 547 U.S. 1, 5 (2006)).
A. There is Daylight Between the Current Facts of this Case and Topco and Sealy
Defendants argue that ESAs alone are not per se unlawful and that, with the elimination of
NBE, Providers’ Section 1 claims should be subject to the Rule of Reason. Providers maintain that
there is “no daylight between this case and Topco and Sealy,” and that those cases dictate a finding
that ESAs alone are per se unlawful. (Doc. # 2747 at 19). The court disagrees.
In United States v. Sealy, Inc., the licensor, Sealy, agreed to allot exclusive territories to its
licensee-members, a group of mattress manufacturers. 388 U.S. 350, 352 (1967). Sealy also,
however, set the prices its members could charge for their products. Sealy, 388 U.S. at 354-55.
Therefore, as the Supreme Court noted, “[i]n the present case, we are [] faced with an ‘aggregation
of trade restraints.’” Id. at 354. In Sealy, the “territorial exclusivity[’s] connection with the
unlawful price-fixing [was] enough to require that it be condemned as an unlawful restraint[].” Id.
at 356-57. Under these facts, the Supreme Court held that “territorial limitations [that] are part of

‘an aggregation of trade restraints’ [] are unlawful under § 1 of the Sherman Act without the
necessity for an inquiry in each particular case as to their business or economic justification, their
impact in the marketplace, or their reasonableness.” Id. at 357-58. The court in Sealy, like this
court previously, did not evaluate the issue of a horizontal market allocation alone. Rather, the
Sealy Court was confronted with an aggregation of trade restraints. So, the posture of the claims
in Sealy was similar to what this court faced when it issued its 2018 ruling. But, now that the NBE
rule has been eliminated, this court is not dealing with the same aggregation of restraints, at least
for purposes of assessing (1) injunctive relief and (2) damages beginning in April 2021.
In United States v. Topco Associates, Inc., a group of small and medium-sized supermarket

chains associated together to sell private-label goods under Topco’s brand names. 405 U.S. 596,
598, 601-02 (1972). Membership in the association had to be “approved by the board of directors,
and thereafter by an affirmative vote of 75% of the association’s members.” Topco, 405 U.S. at
602. “[T]he procedure for approval provide[d], in essence, that members have a veto of sorts over
actual or potential competition in the territorial areas in which they are concerned.” Id. Nothing in
Topco, however, indicates that any of the member chains had any right to use the Topco brand
prior to becoming a member of the association. Id. (“Following approval, each new member signs
an agreement with Topco designating the territory in which that member may sell Topco-brand
products.” (emphasis added)). The fact that, here, the Blue Plans had at least some sort of
preexisting common law trademark rights to the Blue Marks before the License Agreements
memorialized or settled those rights is a distinction with a difference. Therefore, Topco is also
distinguishable on these grounds.
Of course, “the mere fact that an agreement implicates intellectual property rights does not
“immunize [the] agreement from antitrust attack.” 1-800 Contacts, Inc. v. Fed. Trade Comm’n, 1

F.4th 102, 113 (2d Cir. 2021) (quoting FTC v. Actavis, 570 U.S. 136, 147 (2013) and citing In re
Indep. Serv. Orgs. Antitrust Litig., 203 F.3d 1322, 1325 (Fed. Cir. 2000) (“Intellectual property
rights do not confer a privilege to violate the antitrust laws.”)). However, “[a]greements to protect
trademarks [] should not immediately be assumed to be anticompetitive – in fact, Clorox tells us
instead to presume they are procompetitive.” 1-800 Contacts, 1 F.4th at 116 (citing Clorox Co. v.
Sterling Winthrop, Inc., 117 F.3d 50, 55-56 (2d Cir. 1997) (“Such agreements are common, and
favored, under the law.”)).
In 2018, this court discounted Defendants’ trademark justification for ESAs when it
considered the aggregation of ESAs and NBE because “there [was] nothing in the Rule 56 record

which indicate[d] that there [was] any valid connection between trademark rights and the National
Best Efforts rule.” In re Blue Cross Blue Shield Antitrust Litig., 308 F. Supp. 3d at 1272. Where
restraints are derived from trademark agreements, however, they “could plausibly be thought to
have a net procompetitive effect[]. 1-800 Contacts, 1 F.4th at 116. (“Crucially, the restraints at
issue here could plausibly be thought to have a net procompetitive effect because they are derived
from trademark settlement agreements.”). In light of 1-800 Contacts, and the elimination of the
NBE rule, Defendants’ argument that the ESAs arose from common law trademark rights warrants
a closer look. “[E]ven though trademark agreements inherently prevent competitors ‘from
competing as effectively as [they] otherwise might’ [] ‘it is difficult to show that an unfavorable
trademark agreement creates antitrust concerns.’” 1-800 Contacts, 1 F.4th at 119 (citing Clorox,
117 F.3d at 55, 57).
In VMG Enterprises, Inc. v. F. Quesada & Franco, Inc., cited by Defendants, two
manufacturers of baby diapers (VMG and non-party UCI) separately acquired the right to use the
mark “BABY’S CHOICE” in their own geographies. 788 F. Supp. 648, 651, 654 (D.P.R. 1992).

Following competing filings to register their respective marks, VMG and UCI entered into a
concurrent use agreement in which they agreed that each manufacturer could use the mark in its
exclusive territorial region, which for VMG included Puerto Rico. VMG, 788 F. Supp. at 651-52,
657. VMG then sued the defendant, who was selling baby diapers in Puerto Rico under the name
“BABY’S CHOICE.” Id. at 650. The defendant filed a counterclaim asserting the “theory [that]
VMG’s and UCI’s concurrent use registrations are based on agreements which divide trademark
territories” and therefore violate antitrust laws. Id. at 657. The court disagreed. It reasoned that
“the territorial division in question is legitimate under both common law and by statute, as intended
to promote the underlying principles of the trademark laws in general and the Lanham Act,”

including the “protection of a party’s investment in developing the goodwill of its products.” Id.
(citing In re Beatrice Foods Co., 429 F.2d 466, 472, n.10 (3d. Cir. 1970) (discussing the legislative
history of the Lanham Act)). Moreover, the court held, “[t]he concurrent use agreement, and the
registration that followed it, did not ‘create’ a trademark territorial division for the BABY’S
CHOICE mark between VMG and UCI; it merely recognized it.” Id. “[T]he division was already
a reality as a matter of trademark law.” Id.
Something similar can be said about the Blue Marks and the ESAs in this case. Prior to the
introduction of the License Agreements with the Association and with its predecessors, the Blue
Plans had been using the Blue Marks and had already acquired at least some common law
trademark rights in the Marks.
Providers dispute that the Blue Plans had any preexisting common law trademark rights to
the Blue Marks. (Doc. # 2747 at 15-16). Providers argue that any common law rights to the Marks
were abandoned through “naked licensing,” or, alternatively, that the Plans were mere licensees of

national organizations. However, as they admit, “1954 Blue Cross [license] agreement and the
1952 Blue Shield [license] agreement [] describe pre-existing rights in the Blue Cross and Blue
Shield marks.” (Doc. # 2747 at 8, ¶ 21). Those agreements came about to provide clarity on the
rights to the Blue Cross and Blue Shield marks following the passage of the Lanham Act. (Doc. #
2735 -5 at 4; Doc. # 2735 at 6; Doc. # 2735-8). And, agreements settling trademark rights “are not
so obviously anticompetitive to consumers that someone with only a basic understanding of
economics would immediately recognize them to be so.” 1-800 Contacts, Inc. 1 F.4th at 117.
Furthermore, such a “settlement” of trademark rights need not arise from litigation. In 1-800
Contacts, one of the trademark agreements at issue arose out of a business arrangement between

1-800 Contacts and a lens supplier, Luxottica—not any direct threat of litigation. 2021 WL
2385274, at *3.
In any event, the court need not define the exact nature or extent of the Blue Plans’ common
law rights in the marks. According to Clorox, “[w]e begin with the fact that [Providers] challenge
a trademark agreement [which] are common, and favored, under the law.” Clorox, 117 F.3d at 55
(citing 2 J. Thomas McCarthy, McCarthy on Trademarks and Unfair Competition § 18:25 (4th
ed.1996)). Importantly, ESAs “do[] no more than regulate how the [Blue Mark] may be used;
[they] do[] not in any way restrict [a Blue Plan] from producing and selling products that compete
directly with the [Blue] brand, so long as they are marketed under a brand name other than [a Blue
Mark].” Clorox, 117 F.3d at 57. ESAs, and the License Agreements effecting them, “[do] not
restrict a competitor’s ability to market products under names other than the one precluded by the
agreement,” i.e., the Blue Marks. Id. (citing California Packing Corp. v. Sun-Maid Raisin
Growers, 165 F. Supp. 245 251 (S.D. Cal. 1958), aff’d, 273 F.2d 282 (9th Cir. 1959)). That is, the
ESAs do not limit a Blue Plan’s ability to operate under non-Blue brands. It was the now-defunct

NBE rule that operated to preclude that. Without NBE, even under the Blues’ ESAs, the Plans are
free to enter into any market under a non-Blue brand. The only market in which the Blue Plans’
ability to compete under a non-Blue brand is limited is the market to which their License
Agreement applies, and in that market they are already naturally disincentivized to operate a non-
Blue business there because they would be competing against themselves.
Because (1) courts “presumptively” apply a “rule of reason analysis” NCAA, 141 S. Ct. at
2151, (2) trademark agreements are “common, and favored, under the law,” Clorox, 117 F.3d at
55, and (3) trademark agreements do not immediately appear “obviously anticompetitive,” 1-800
Contacts, Inc. 1 F.4th at 117, the court concludes that the appropriate standard of review under

which the court will evaluate ESAs alone is the Rule of Reason. The court emphasizes that this
holding is applicable only to the period of time following the elimination of the NBE rule in April
2021.
B. NBE Is Relevant to Providers’ Claims
Defendants argue that Providers’ Section 1 claims should be evaluated under the Rule of
Reason for the entire class period, rather than just following the elimination the NBE rule, because
NBE was a Subscriber-facing rule that has nothing to do with Provider claims. (Doc. # 2728 at 34-
36 (“NBE was a subscriber-facing rule that governed solely the percentage of subscriber-related
revenue that a Plan may earn from non-Blue-branded sales on a nationwide basis.”) (emphasis in
original)). The court disagrees.
Providers respond that they have asked for relief in relation to NBE from the beginning of
this case. Indeed, in their Consolidated Fourth Amended Complaint, Providers summarized the
basis for their Market Allocation Conspiracy claims as follows:

In furtherance of the Market Allocation Conspiracy, Defendants agreed that each
Defendant would be allocated a defined Service Area and further agreed that each
Defendant’s ability to operate and to generate revenue outside its geographic
Service Area would be severely restricted.
(Doc. # 1083 at ¶ 5) (emphasis added). They further alleged that:
The non-Blue revenue restriction agreement, which the Blues call “best efforts
rules” to hide the obvious anti-competitive effects of this agreement also reinforces
the other agreements and prevents the Defendants from engaging in meaningful
competition in any manner.
(Id. at ¶ 15). Providers also alleged that the effect of NBE is to “put[] an artificial limit on
competition” and “reduce[] the incentive for the Blues to develop business out of their Service
Areas because they know that the potential for that business is limited.” (Id. at ¶ 365). In their brief
in response to Defendants’ July 2017 Motion for Summary Judgment, Providers included a section
headed, “[t]he “Best Efforts” Rules Are Unlawful Limitations on Output.” (Doc. # 1431 at 61).
They argued that “the Blues’ limits on non-Blue revenue [NBE] restrain potential competition.”
(Id. at 32).
Defendants are wrong that NBE is only relevant to the Subscriber case. Providers have also
alleged that NBE is part of their Market Allocation Conspiracy claim. And restricting the
development of non-Blue insurance options for Subscribers could also have the effect of reducing
the options available to Providers to contract with non-Blue health insurers. Therefore, Providers’
Section 1 Market Allocation Conspiracy claims involving the aggregation of ESAs and NBE will
remain subject to the court’s 2018 standard of review decision for the period of time before NBE
was eliminated.
IV. Conclusion
For all of the foregoing reasons, Defendants’ Motion Regarding the Antitrust Standard of
Review Applicable to Provider Plaintiffs’ Section 1 Claims (Doc. # 2722) is GRANTED IN
PART AND DENIED IN PART.
The Motion is GRANTED to the extent that the court concludes that ESAs, viewed alone
divorced from NBE), “should not immediately be assumed to be anticompetitive,” /-800
Contacts, 1 F.4th at 116, and thus are not “naked restraint[s] of trade with no purpose except
stifling competition.” Levine v. Cent. Fla. Med. Affiliates, Inc., 72 F.3d 1538, 1550 (11th Cir.
1996). Therefore, for the period of time following the elimination of the NBE rule (after April
2021), the court concludes that it must apply the rule of reason analysis to Providers’ Market
Allocation Conspiracy claims.
In all other respects, the Motion is DENIED.
DONE and ORDERED this August 9, 2022.

UNITED STATES DISTRICT JUDGE

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/9991246. Public record. Not legal advice.